NEPGA and several parties to the Peak Energy Rent hearing and settlement conference filed a reply to comments filed by the New England States Committee on Electricity (NESCOE) (Nos. EL16-120 and ER17-2153).  In a settlement filed in July, the parties (including NEPGA and NESCOE) agreed to an increase in the Peak Energy Rent (PER) Strike Price, the Real-Time Energy Market price above which PER charges begin to accrue.  In its comments, NESCOE asked FERC to find that the increase to the PER Strike Price ordered by FERC ceases to have any effect on PER charges to capacity payments made during the Ninth Capacity Commitment Period.  NEPGA, et al., asks FERC to reject NESCOE’s request, arguing that the Tariff provides that the increased PER Strike Price continues to apply to PER charges caused by PER Events in the Eighth Capacity Commitment Period that have an effect on Ninth Capacity Commitment Period capacity payments, and that NESCOE is impermissibly asking for a tariff change in its comments on a settlement agreement.